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FMC Procedure Document Name: SPCC Plan Approval Date: 1/30/2010 Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC 5470 Created 1/30/10 Generated by: AMEC/MJM X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLAN Denton, Texas January 2010 Revision 2: July 2014

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Page 1: SPILL PREVENTION CONTROL · X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc II. SPCC PLAN REVIEW – 40 CFR 112.5 (b)

FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

Generated by: AMEC/MJM

X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc

SPILL PREVENTION CONTROL AND COUNTERMEASURE

(SPCC) PLAN

Denton, Texas

January 2010 Revision 2: July 2014

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

Generated by: AMEC/MJM

X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc

TABLE OF CONTENTS

SECTION PAGE

I. PROFESSIONAL ENGINEER’S CERTIFICATION – 40 CFR 112.3(d) ......................1

II. SPCC PLAN REVIEW – 40 CFR 112.5 (b) .......................................................................2

III. MANAGEMENT APPROVAL – 40 CFR 112.7 ................................................................3

IV. INTRODUCTION – 40 CFR 112.5(a) .................................................................................3

V. SPCC POSTED AT FACILITY – 40 CFR 112.3(e) ..........................................................5

VI. FACILITY RESPONSE PLAN – 40 CFR 112.20(f) ..........................................................6

VII. FACILITY INFORMATION ..............................................................................................6

VIII. FACILITY LOCATION AND DESCRIPTION – 40 CFR 112.7(a)(3) ...........................7

IX. FACILITY OIL STORAGE CAPACITY DESCRIPTION – 40 CFR 112.7(a)(3)(i) .....8

X. POTENTIAL SPILL DIRECTIONS VOLUMES AND RATES – 40 CFR 112.7 (b) ....9

XI. CONTAINMENT AND DIVERSIONARY STRUCTURES – 40 CFR 112.7(C) &

112.8(C) (2) ....................................................................................................................11

XII. DEMONSTRATION OF PRACTICABILITY – 40 CFR 112.7(D) ...............................11

XIII. PERSONNEL, EDUCATION AND DISCHARGE PREVENTION PROCEDURES –

40 CFR 112 .7(f) ............................................................................................................12

XIV. SECURITY – 40 CFR 112.7 (g) .........................................................................................13

XV. FACILITY TANK CAR & TRUCK UNLOADING/LOADING – 40 CFR 112.7(H) ..13

XVI. BRITTLE FRACTURE – 40 CFR 112.7(I) ......................................................................14

XVII. FACILITY DRAINAGE – 40 CFR 112.8(B) ..............................................................14

XVIII. BULK STORAGE TANKS – 40 CFR 112.8(C) .........................................................14

XIX. SECONDARY CONTAINMENT DRAINAGE – 40 CFR 112.8 (C)(3) ........................14

XX. INSPECTION AND RECORDS – 40 CFR 112.8 (C)(6) .................................................14

XXI. PORTABLE OIL STORAGE – 40 CFR 112.8 (C)(11) ...................................................16

XXII. FACILITY TRANSFER OPERATIONS – 40 CFR 112.8 (D) .................................16

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

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XXIII. SPILL RESPONSE AND EMERGENCY PROCEDURES .....................................17

XXIV. PLAN IMPLEMENTATION – 40 CFR 112.3(A) ......................................................20

FIGURES

Figure 1 Site Vicinity Map

Figure 2 Site Plan, Sheets 1 and 2

TABLES

Table 1 Emergency Generator List

Table 2 Oil-Filled Transformer List

Table 3 Hydraulic Elevator List

Table 4 Miscellaneous Oil-Containing Equipment List

Table 5 Past Spill History

Table 6 Spill Prevention Equipment

APPENDICES

Appendix 1 Procedures

Oil Spill Response Procedure

Oil Transfer Procedure

General Handling Oil Procedures

Appendix 2 Statement of Substantial Harm Determination

Appendix 3 Initial Notification Form

Appendix 4 SPCC Training Outline

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

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I. PROFESSIONAL ENGINEER’S CERTIFICATION – 40 CFR 112.3(d)

I hereby certify that my agent, Mr. Matt Moustakas, has visited and examined the facility,

and being familiar with the provisions of Title 40, Code of Federal Regulations Part 112,

attest that this Spill Prevention Control and Countermeasure (SPCC) Plan has been prepared

in accordance with good engineering practices, including consideration of applicable industry

standards, and with the requirements of Title 40, Code of Federal Regulations (CFR) Part

112. Procedures for required inspections and testing have been established and this Plan is

adequate for the facility.

(Seal)

Mr. Joe Standridge, P.E.

Texas Professional Engineer

Signature of Registered

Texas Professional Engineer

Date:

Registration No.:

State: Texas

Facility: Texas Woman’s University

Location: Denton, Texas 76209

Date of Plan: 7/28/14

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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II. SPCC PLAN REVIEW – 40 CFR 112.5 (b)

In accordance with 40 CFR 112.5(b), the owner/operator of the facility will conduct a review

and evaluation of this Spill Prevention Control and Countermeasure (SPCC) Plan at least

once every 5 years. Texas Woman’s University will amend the SPCC Plan within 6 months

of the review to include more effective prevention and control technology if: (1) such

technology will significantly reduce the likelihood of a discharge from the facility, and (2) if

such technology has been field-proven at the time of review. Evidence of these reviews shall

be recorded below.

“I have completed a review and evaluation of the SPCC Plan for the Texas Woman’s

University located in Denton, Texas on ______________________ (date) and

(will/will not) amend the Plan* as a result.”

__________________________________________

(Signature)

__________________________________________

(Name and Title)

“I have completed a review and evaluation of the SPCC Plan for the Texas Woman’s

University located in Denton, Texas on ______________________ (date) and

(will/will not) amend the Plan* as a result.”

__________________________________________

(Signature)

__________________________________________

(Name and Title)

* A PROFESSIONAL ENGINEER MUST CERTIFY TECHNICAL AMENDMENTS TO THE PLAN. PE

CERTIFICATION IS NOT REQUIRED FOR NON-TECHNICAL AMENDMENTS SUCH AS

CHANGES TO PHONE NUMBERS, NAMES, ETC.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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III. MANAGEMENT APPROVAL – 40 CFR 112.7

The management of the Texas Woman’s University located in Denton, Texas hereby

approves this SPCC plan and is fully committed to the implementation of the SPCC Plan as

described herein.

________________________________________________________________

Matt Moustakas

Director of Environmental, Safety & Health

_______________________________________

Date

IV. INTRODUCTION – 40 CFR 112.5(a)

This Spill Prevention Control and Countermeasure (SPCC) Plan has been prepared for the

Texas Woman’s University (TWU) located in Denton, Texas. This SPCC Plan was prepared

to meet the following objectives:

To detail the operating procedures to reduce the possibility of oil discharges;

To specify control measures to be followed to reduce the possibility of a discharge

from entering navigable waters (as defined in the regulations outlined below);

To outline countermeasures to contain, clean-up, and mitigate the effects of a

discharge that may impact navigable water; and

To provide a guideline for notifying state and federal agencies in the event of a

discharge.

This SPCC Plan has been developed in accordance with the requirements of the U.S.

Environmental Protection Agency (EPA) Title 40, Code of Federal Regulations, Part 112 (40

CFR 112), “Oil Pollution Prevention.” The Federal Water Quality Improvement Act of

1970, the primary law which governs the discharge of oil into or upon navigable waters of

the United States, prohibits the discharge of oil in quantities which may be harmful to the

public health or welfare or the environment of the United States. “Oil Pollution Prevention”

(40 CFR 112) was promulgated in 1973 pursuant to Section 311 of the Federal Water

Pollution Control Act Amendments of 1972.

On July 17, 2002, EPA published modifications to the SPCC requirements in the Federal

Register (Volume 67, No. 137, pages 47041-47152). Changes were effective August 16,

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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2002. The EPA has granted several extensions to the compliance dated proposed in 40 CFR

112.3(a) and (b). On April 1, 2009, the reference compliance dates were extended to require

an onshore or offshore facility in operation prior to August 16, 2002, to amend its plan to

ensure compliance on or before November 10, 2010, and to implement the amended plan as

soon as possible, but no later than November 10, 2010. A facility that becomes operational

after August 16, 2002, through November 10, 2010, and could reasonably be expected to

have a discharge as described in 40 CFR 112.1(b) must prepare a Plan on or before

November 10, 2010, and fully implement it as soon as possible but no later than November

10, 2010. A facility that becomes operational after November 10, 2010, and could

reasonably be expected to have a discharge as described in 40 CFR 112.1(b) must prepare

and implement a Plan before it begins operations.

According to 40 CFR 112.2, oil is defined as “oil of any kind or in any form, including, but

not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils,

including oils from seeds, nuts, fruits, or kernels; and other oils and greases, including

petroleum, fuel oil, sludge, synthetic oil, mineral oils, oil refuse, or oil mixed with wastes

other than dredged spoil.” Discharge includes, but is not limited to, any spilling, leaking,

pumping, pouring, emitting, emptying or dumping. Navigable waters include “all navigable

waters of the United States…and tributaries of such waters.” As defined in 40 CFR 110.3,

discharges of oil in such quantities deemed to be harmful to the public health or welfare of

the United States include discharges that:

Violate applicable water quality standards; or

Cause a film or sheen upon or discoloration of the surface of the water or adjoining

shorelines or causes a sludge or emulsion to be deposited beneath the surface of the

water or upon adjoining shorelines.

According to 40 CFR 112, an SPCC Plan must be prepared and implemented by a facility if a

discharge from the facility could reasonably be expected to discharge oil in harmful

quantities as defined in 40 CFR 110 into or upon the navigable waters of the United States or

adjoining shorelines due to its location and if any of the following conditions apply:

The aggregate aboveground oil storage capacity of the facility is greater than 1,320

gallons; or

The completely buried oil storage capacity of the facility is greater than 42,000

gallons.

The following chart summarizes SPCC Plan applicability criteria and this facility’s status

relative to these requirements.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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Texas Woman’s University

SPCC Plan Applicability Criteria

Applicability Criteria Texas Woman’s University

Conditions

SPCC Plan

Required

A. Total underground volume greater than

42,000 gallons

No

Total = 11,000 gallons

No

B. Total aboveground volume greater than

1,320 gallons

Yes

Transformers 8,672,

Emergency Generators 4,623,

ASTs 35,255 gallons

Yes

C. Reasonably expected to discharge oil in

harmful quantities to navigable water

Yes

Proximity to navigable

waterways*

Yes

*The potential for spills or leaks of harmful quantities of oil to enter the storm drain system. Surface drainage is

designed, in part, to flow into the waterway located on the TWU golf course on the eastern portion of campus and

drains into the City storm drains on the western portion of the campus.

The requirement to prepare an SPCC Plan is applicable to the TWU campus in Denton,

Texas based on its status as a non-transportation-related onshore facility which stores oil or

oil products in excess of the above-listed threshold values and which, based on its location,

could reasonably be expected to discharge oil in quantities that may be harmful into or upon

the navigable waters of the United States or adjoining shorelines.

Per 40 CFR 112.5(a), this SPCC Plan must be amended whenever there is a change in facility

design, construction, operation or maintenance, which materially affects the potential for a

discharge. Furthermore, per 40 CFR 112.4, the United States EPA Regional Administrator

may require amendment of the SPCC Plan whenever the facility has:

Discharged more than 1,000 gallons of oil into or upon the navigable waters of the

United States or adjoining shorelines in a single discharge;

-or-

Discharged more than 42 gallons of oil in each of two discharges into or upon

navigable waters of the United States or adjoining shorelines, occurring within any

12-month period.

Technical amendments to the SPCC Plan shall be certified by a registered Professional

Engineer and must be implemented within 6 months. Amendments will be forwarded to all

persons having copies of this SPCC Plan for insertion into the SPCC Plan.

V. SPCC POSTED AT FACILITY – 40 CFR 112.3(e)

Pursuant to 40 CFR 112.3(e) a complete copy of the SPCC Plan shall be maintained at the

facility by the facility owner or operator, if the facility is attended for at least four hours per

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

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day.

The facility is attended at least four hours per day and for this reason a copy of the facility

SPCC Plan is available at the TWU. The SPCC Plan is located at 1200 Frame Street in

Denton, Texas, specifically in the Director of Environmental, Safety and Health’s Office.

VI. FACILITY RESPONSE PLAN – 40 CFR 112.20(f)

While the preparation of an SPCC Plan is required for oil management, this facility is not

required to prepare a Facility Response Plan as defined in 40 CFR 112.20. Facility Response

Plans are required for non-transportation-related onshore facilities that, because of their

location, could reasonably be expected to cause substantial harm to the environment by

discharging oil into or on the navigable waters or adjoining shorelines. Based on the fact that

this facility does not transfer oil over water to or from vessels (based on U.S. EPA criteria)

and does not have a total oil storage capacity greater than or equal to 1 million gallons, the

preparation and submittal of a Facility Response Plan is not required, unless it is required at a

future date at the discretion of the U.S. EPA Regional Administrator. Pursuant to Section 3.0

of Appendix 3 to 40 CFR 112, certification of the non-applicability of the substantial harm

criteria is provided. This certification is provided as Appendix 2.

VII. FACILITY INFORMATION

Name of Facility: Texas Woman’s University

Street Address: The portion of the TWU campus covered by this

Plan is generally bounded by University Drive

to the north; North Locust Avenue to the west;

Texas Street to the south; and the Golf Course

to the east. Additional adjacent properties have

been or will be acquired for campus expansion,

see Figure 1.

Mailing Address: Texas Woman’s University

P.O. Box 425619

Denton, Texas 76209

Owner: Texas Woman’s University

Designated Person Accountable for

Oil Spill Prevention at the Facility: Mr. Matt Moustakas, Director of

Environmental, Safety and Health

940-898-2924 (Business)

940-465-4084 (Emergency)

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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See Section XXIII: Spill Response and Emergency Procedures for a complete list of emergency contacts.

VIII. FACILITY LOCATION AND DESCRIPTION – 40 CFR 112.7(a)(3)

The Texas Woman’s University (TWU) is located in Denton, Texas. TWU was originally

established in 1901, opening its doors in 1903 with a current enrollment of approximately

14,200 students in 2010. The facility location is shown on Figure 1.

In June 1998, TWU installed two underground storage tanks (USTs) located at the Facilities

Management Center (FMC) consisting of one 10,000-gallon UST containing gasoline and

one 1,000 gallon UST containing diesel. Both USTs are fiberglass-reinforced plastic (FRP)

double wall tanks with a factory-built nonmetallic jacket with interstitial monitoring within

the secondary wall/jacket. Automatic line leak detectors and automatic high level alarms

with automatic delivery shut-off valves were installed.

The electrical infrastructure has changed from electrical power being supplied to the North

and South Substations by an outside provider to the campus, to currently operating a high

voltage loop connected to the city power, and stepping voltage down, as appropriate, at each

building. TWU personnel maintain the transformers and emergency generators located on

campus. Currently, TWU has twelve emergency generators with associated diesel-containing

above ground storage tanks (ASTs) with a total fuel volume of 4,484 gallons. All

transformers and several generators have been replaced since the initial plan was prepared.

Two-15,000 gallon ASTs containing diesel are located at the Central Plant. Fuel is

transferred from the ASTs to boilers through aboveground piping. One double-walled 55-

gallon used oil tank is also located at the Central Plant adjacent to the ASTs.

Forty-two oil-filled electrical transformers are located throughout the TWU campus on

concrete pads. An estimated volume of dielectric oil for these transformers is between 8,000

and 9,000 gallons; one of the units is new and its volume is unknown.

Twenty hydraulic elevators are located within fifteen buildings. Elevators are inspected on

an annual basis. The locations of the elevators are found in Table 3.

Six oil/water separators (OWS) are located at TWU, five of which are for the collection of

food preparation grease in kitchen areas. The Auto Shop at the FMC Service Center is

equipped with a sand trap and OWS that are occasionally used to wash vehicles. The sand

trap is located in the vehicle bay used to wash vehicles, and is equipped with a floor grate.

The sand trap and floor drains in the other vehicle bays drain to the OWS. The sand trap and

OWS in the Auto Shop are also used for spill capture of used or new oil. The Auto Shop

maintains various quantities of 55-gallon drums of new and used oil. Containers stored

outdoors or near the roll-up door are stored on secondary containment pallets, other

containers would be contained by the building with excess draining to the sand trap and/or

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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OWS. A trench drain is located outside the Auto Shop south of the building (with its own

sand trap) near the southeast corner and is piped to the sanitary sewer. This trench drain is

used for vehicle cleaning. A valve on the trench drain is kept closed and is opened only

when a vehicle is washed.

Two kitchen areas, the Student Center kitchen and the Nutrition and Food Science kitchen in

the Human Development Building (HDB), manage used cooking grease. The Student Center

kitchen uses a 5-gallon container to transfer grease to a used-grease container located in the

loading dock area for disposal. The Nutrition and Food Science kitchen stores cooking

grease in a 55-gallon drum and the disposal contractor transports the drum to the ground

floor for disposal.

Two USTs are located at the FMC Service Center and store gasoline (10,000 gallon) and

diesel (1,000 gallon) for refueling of various types of equipment used at TWU. TWU

personnel utilize a truck-mounted diesel-containing AST to refuel emergency generator

ASTs. Fuel for the ASTs is obtained from the diesel UST located at the Service Center. The

mobile tank is a steel single-wall container equipped with an electric pump and typical

flexible hose and nozzle for transferring of fuel to each generator tank and is generally

parked by the Auto Shop at the FMC Service Center. The Service Center also maintains an

approximately 500-gallon double wall used oil tank that is located in the Golf Cart Barn

adjacent the FMC Service Center. Tables 1, 2, 3, and 4 contain information regarding oil-

containing equipment located at TWU.

Table 5 summarizes past spills that have been reported to FMC or Risk Management.

IX. FACILITY OIL STORAGE CAPACITY DESCRIPTION – 40 CFR

112.7(a)(3)(i)

The TWU facility maintains the following oil storage in capacities equal to or greater than

55-gallons:

Storage Type Category Units Present

Underground storage tanks Bulk storage container 2 USTs

Above ground storage tanks Bulk storage container 2 ASTs

Emergency generator tanks Bulk storage container 12 ASTs

Oil-filled Transformers Equipment 42 regulated units

Elevator hydraulic tanks Equipment 20 units

Oil/Water Separators Equipment 6 units, one with upstream sand trap

55-gallon drums Bulk storage container 3 cooking grease and various new and

used oil drums

Refueling Tank Bulk storage container 1 AST

Used oil storage tank Bulk storage container 1 55-gallon AST and 1 500-gallon AST

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

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Storage of oil in bulk storage containers is specifically defined at 40 CFR 112.2 as follows:

“Bulk storage container means any container used to store oil. These containers are

used for purposes including, but not limited to, the storage of oil prior to use, while

being used, or prior to further distribution in commerce.

Bulk oil storage containers include both ASTs and 55-gallon drums. These containers are

subject to numerous technical provisions of SPCC regulations including:

Periodic integrity testing of bulk oil storage containers [40 CFR 112.7(d)],

Requirements for secondary containment [40 CFR 112.8(c)(2) or 112.8(c)(11)],

Inspection of secondary containment effluent, if any, prior to discharge [40 CFR

112.8(c)(3)],

Testing and inspection and recordkeeping for the AST on a regular basis [40 CFR

112.8(c)(6)],

Provision for high liquid level alarms or high liquid level pump cutoff or direct

audible signal between the container and pumping station or a fast response system

for determining the liquid level [40 CFR 112.8(c)(8)],

Inspection of piping and valving [40 CFR 112.8(d)(4)], and

Security including illumination, and locking fill and discharge points [40 CFR

112.7(g)].

As indicated by the definition of bulk oil storage container at 40 CFR 112.2:

“Oil-filled electrical, operating, or manufacturing equipment is not a bulk storage

container.”

The operational use of oil is exempt from the secondary containment required for bulk

storage containers (40 CFR 112.8(c)). However, the operational use of oil is still subject to

other SPCC requirements, including the general requirements of 40 CFR 112.7(c) to provide

appropriate containment and/or diversionary structures to prevent discharged oil from

reaching a navigable watercourse. This more general requirement meets the needs of Section

311(j)(1)(C) of the CWA.

The storage container locations and capacities are listed in Tables 1, 2, 3, and 4. The

locations of the emergency generators and oil-filled transformers are shown on Figure 2.

X. POTENTIAL SPILL DIRECTIONS VOLUMES AND RATES – 40 CFR 112.7

(b)

The potential exists for a discharge or release of oil from storage tanks, piping, or oil transfer

operations to occur at the facility. Potential release scenarios are identified in Tables 1, 2, 3,

and 4, and are based on a worst-case event (i.e., failure of the largest single tank or the largest

tank truck compartment in a given area). These tables also provide the estimated rate that

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would be associated with a given release.

In general, spill events at the facility may occur during routine filling operations or due to

unforeseen events such as corrosion failure of the tank or piping system or breaks or leaks in

the tank or fuel transfer piping. Spill events resulting from fuel transfer would be limited to

the volume of oil present in the largest compartment of the fuel supply vehicle, generally

5,000-gallons or less. However, control measures including fully manned operations will

reduce the potential for spill events of this magnitude.

The inferred flow direction of oil spills is shown on Figure 2 for emergency generators and

transformers at the facility. Drainage and oil spill flow patterns are anticipated to follow the

site topography in the immediate area of any potential spill or release event.

Emergency generators are double walled with sight gauges. Four emergency generators;

located at the Graduate Research Building (GRB), Guinn and Stark Halls and the

Administrative and Conference Tower (ACT); are located adjacent to a storm drain or floor

drain that could receive fluids during a spill/leak event.

Leaks of hydraulic oil from transformers are anticipated to be minimal and would be

anticipated to occur only at locations where seals or gaskets are degraded or as the result of

catastrophic events such as vandalism or vehicular collision. In general, minor releases of

dielectric fluids at transformers are anticipated to flow down the outside of the transformer to

the concrete pad upon which the transformer sits.

Elevator oil reservoirs are contained within the building they service; therefore, there is no

potential to discharge outside the building.

The used cooking grease drum located in the HDB Nutrition and Food Sciences kitchen

could spill into a floor drain that is connected to the Publicly Owned Treatment Works

(POTW) system or could potentially be spilled during transport to the ground floor via

elevator. Cooking grease could also be spilled during the manual transport from the Student

Center kitchen to the used grease container located outside at the loading dock. Spillage

would travel east towards a trench drain in the center of the loading dock area.

New and used oil located at the FMC Service Center Auto Shop is either stored on heavy

poly drum pallets with the capacity to contain at least 55 gallons of oil, or stored indoors

where leaks and spills would be to the concrete floor and would potentially flow to floor

drains that drain to an OWS.

Fuel spills during the filling of the two USTs would flow to the concrete and then north

towards the Service Center.

The truck-mounted AST used to refuel emergency generators would spill in various

directions depending on where the truck is parked. When the truck is not being used it is

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parked at the Auto Shop at the FMC Service Center. A spill kit will be maintained with the

truck.

XI. CONTAINMENT AND DIVERSIONARY STRUCTURES – 40 CFR 112.7(C) &

112.8(C) (2)

TWU utilizes various equipment and materials to prevent harmful quantities of oil from

reaching navigable waterways or adjoining shorelines. These include pads, booms, drain

covers, and sorbent materials located in readily identifiable locations.

XII. DEMONSTRATION OF PRACTICABILITY – 40 CFR 112.7(D)

The Plan does not deviate from the requirements of 112.7(c), 112.7(h)(1), 112.8(c)(2),

112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), 112.12(c)(11), 112.13(c)(2), and

112.14(c) except for facility dispensing areas where secondary containment has been deemed

impractical. These areas are supplemented with engineering and administrative measures to

prevent a discharge.

Where loading/unloading operations occur, there are two types of applicable operations,

transfer operations and dispensing operations. Transfer operations are designated as

operations involving a truck being connected to tank piping/fill port located on generator

tanks, ASTs, USTs, TWU vehicles, and other equipment. Areas where transfer operations

occur are not equipped with secondary containment. Dispensing operations at the facility are

conducted when a vehicle operator dispenses the tank contents into a truck, equipment or

other vehicle. There are no secondary containment structures relating to dispensing

operations, but spill prevention procedures are in place.

Prior to filling or withdrawing fuel, inspection of the vehicle or equipment is required. Prior

to tank truck departure, all flexible transfer lines must be disconnected, and the lowermost

drain and all other outlets of the vehicle should be closely inspected for any leakage, and if

necessary, tightened, adjusted, or replaced to prevent leakage while in transit.

At the UST fuel island, pumps do not operate without an electronic key and key pad code.

Refueling by a fuel supply vendor is performed under the supervision of an FMC

representative.

Fueling of emergency generators and miscellaneous equipment takes place throughout the

day. FMC personnel transferring fuel at one of the four emergency generators that has a

drain in the immediate vicinity (See Section X above) will ensure that drain covers and other

spill response material/equipment are available for use prior to initiating the transfer.

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XIII. PERSONNEL, EDUCATION AND DISCHARGE PREVENTION

PROCEDURES – 40 CFR 112 .7(f)

The Oil Pollution Prevention regulations require owners and operators of the facility to

properly instruct their oil-handling personnel in the operation and maintenance of equipment

to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules,

and regulations; general facility operations; and, the contents of the facility SPCC Plan.

Discharge prevention briefings are required to be presented to oil-handling personnel and

other affected employees at least once a year to ensure adequate understanding of the SPCC

Plan for the facility. These briefings must highlight and describe known discharges as

described in 40 CFR Section 112.1(b) or failures, malfunctioning components, and any

recently developed precautionary measures. Training of facility personnel is also essential to

ensure that personnel involved with the fueling and maintenance of the petroleum storage

systems know the proper actions to take in the event of a spill or release. Topics discussed

during annual training briefings will include:

A. Proper operation of equipment to help protect against releases/discharges;

B. Applicable local, state, and federal pollution regulations;

C. TWU operations, policies and procedures including tank loading procedures, spill

equipment location and use;

D. Specific provisions of this SPCC Plan, including emergency spill reporting and

notification procedures and contact persons; and

E. Known discharge, failures, malfunctioning equipment and any precautionary

measures developed as a result of such discharges, failures, or malfunctioning

equipment.

Facility personnel who are responsible for accompanying the fuel supply vendor during

fueling operations, and the regular inspection and maintenance of the tank systems shall be

trained in the tank loading procedures, the use of the spill containment/response equipment,

and the proper spill notification and reporting procedures. These personnel must also be

familiar with this SPCC Plan to ensure that in the event of a spill, they are capable of

following the appropriate procedures for spill response and reporting. Personnel SPCC

training must be conducted for the above-identified personnel and whenever new personnel

are assigned the above responsibilities. Records of all SPCC training and briefings shall be

maintained by Risk Management to document compliance with these requirements.

At the fuel island, pumps will not operate without an electronic key and key pad code. Fuel

tankers are met by an FMC representative. Spill equipment is made available for use during

fueling of the USTs, ASTs, generator tanks, and TWU vehicles/equipment. Drain covers or

other spill response materials/equipment will be made available for use during fueling of the

four generators that have drains in the vicinity of the generators (See Section X above).

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Cooking grease transferred from the kitchen areas will be transported by facility personnel

who have been trained in spill prevention. Absorbent material or other spill response

materials/equipment will be available in the event a spill occurs.

In case of spills greater than five gallons, external resources (contractors) have been

identified to assist TWU personnel, if needed. At a minimum, contractors identified to assist

in a spill response have the capabilities to provide emergency response, industrial power

vacuuming, tank and pipeline cleaning, building decontamination, excavation/earthmoving,

and waste transportation and disposal services. FMC is responsible for maintaining this list

and providing contact information to other TWU departments as necessary.

XIV. SECURITY – 40 CFR 112.7 (g)

TWU maintains a campus police/security force (TWU’s Department of Public Safety) that

patrols the university on a 24-hour, 7-days per week basis. The fuel pumps associated with

the USTs at the FMC Service Center will not operate without an electronic key and key pad

code. Emergency generator tanks and oil-filled transformers are located within a locked

metal jacket. Lighting is provided throughout the campus to assist in deterring vandalism.

XV. FACILITY TANK CAR & TRUCK UNLOADING/LOADING – 40 CFR

112.7(H)

Bulk oil unloading is conducted at the two ASTs and two USTs at the facility. The fuel

unloading areas at this facility do not consist of “rack” areas where multiple tanks are filled

by one common fill pipe. Thus, the regulatory requirements specified under 40 CFR

112.7(h), especially those under 112.7(h)(1) requiring a containment system to hold at least

the maximum capacity of any single compartment of a tank car unloaded at the facility, are

not applicable. Instead, spill kits are available nearby to respond to any spills during

unloading operations.

Tank loading for the ASTs and USTs are conducted under the supervision of facility

personnel to ensure that proper procedures are followed and to ensure that a TWU

representative is present in the event of a release. During the transfer of fuel to the storage

tanks, facility and oil delivery vendor personnel shall perform continuous inspections of the

tank truck, fuel hose, the receiving tank, and tank oil level monitoring systems to ensure that

spillage and overfilling do not occur. Typical unloading practices include hose inspection,

securing manifolds and valves, and the use of wheel chock blocks to prevent premature

disconnection of the tank truck from the fill port. Tank gauges and fuel levels should be

inspected prior to filling to ensure that the volume available in the tank is greater than the

volume of fuel to be transferred. Tank trucks in the process of being unloaded must be

attended to at all times during fuel unloading. Transfer procedures are provided in Appendix

1.

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XVI. BRITTLE FRACTURE – 40 CFR 112.7(I)

No field-constructed ASTs exist at this site, thus the requirement for a brittle fracture

evaluation is not applicable.

XVII. FACILITY DRAINAGE – 40 CFR 112.8(B)

The facility drainage system and the inferred direction of oil spills are shown on Figure 2 for

emergency generators and oil-filled transformers. Drainage patterns generally follow site

topography in the immediate area of any potential spill or release event.

In general, stormwater flows via sheet flow and has the potential to discharge to the low-

lying swales and drainage areas during precipitation events. Various swales and storm

drainage structures direct runoff from the eastern portion of TWU to the water drainage

feature located on the TWU Golf Course. The western portion of the campus flows to the

City of Denton storm system.

XVIII. BULK STORAGE TANKS – 40 CFR 112.8(C)

The federal Oil Pollution Prevention regulations governing bulk storage tanks address USTs,

ASTs, and containers with capacities of 55 gallons or greater. The oil storage containers

currently in use at the facility are constructed of materials that are compatible with the

contents and conditions in which they are stored. Spill prevention equipment and operation

is summarized in Table 6.

XIX. SECONDARY CONTAINMENT DRAINAGE – 40 CFR 112.8 (C)(3)

Each AST consists of a double-walled tank. The outer wall is sealed, which prevents

precipitation from entering the containment. Therefore, drainage of rainwater from the

secondary containment is not necessary.

XX. INSPECTION AND RECORDS – 40 CFR 112.8 (C)(6)

The Oil Pollution Prevention regulations require that inspections and tests be conducted in

accordance with written procedures that are developed by the facility or certifying engineer.

Written procedures and a record of inspections and tests, signed by the appropriate supervisor

or inspector, must be kept with the SPCC Plan for a period of at least three years (40 CFR

Section 112.7(e)). The inspections are conducted to detect potential equipment problems that

can lead to spills of oil. Inspection frequency varies depending on the type and use of the

equipment. A visual inspection is the simplest way to detect deteriorated, corroded or failed

equipment. During inspections, facility personnel may discover deficiencies in equipment or

in procedures that should be reported to FMC immediately. Since corroded parts of oil-

containing equipment will eventually lead to leakage and rupture, early detection and

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replacement of faulty equipment is necessary to prevent oil spills.

TWU will implement an inspection and monitoring program for the oil storage tanks,

emergency generator tanks and potential oil spill and drainage areas. Facility personnel will

visually inspect and document the condition of bulk oil storage containers on a regular basis.

ASTs located at the Central Plant will be inspected nightly, and emergency generators will be

inspected at least monthly. Elevators will have an annual inspection performed by an outside

contractor.

Inspection logs must be completed and signed by the person conducting the inspection, and

the original signed records maintained on site. These inspections are completed by FMC

personnel or contractors familiar with the oil-containing systems and this SPCC Plan, to

ensure that the equipment is maintained in an operational and safe condition.

The tank inspections are documented on inspection checklists and generally include the

following:

Inspection of exterior surfaces of tanks, pipes, valves, and other equipment for leaks

and maintenance deficiencies;

Identification of cracks, areas of wear, corrosion and thinning, poor maintenance and

operating practices, excessive settlement of structures, separation or swelling of tank

insulation, malfunctioning equipment, and structural and foundation weaknesses;

Inspection of all aboveground valves and piping associated with the tanks including

the general condition of items such as flange joints, expansion joints, valve glands

and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces;

Inspection of tank supports and foundations;

Inspection of leak detection systems or other monitoring or warning systems that may

be in place at the facility; and

Inspection of spill response equipment to ensure that it is present and fully stocked.

In addition to visual inspections of the aboveground oil storage tank system, federal

regulations (40 CFR Section 112.8(c)(6)) require that bulk storage containers be subject to

periodic integrity testing and whenever material repairs are made. The frequency of and type

of testing shall take into account the container size and design. Visual inspection must be

combined with another testing technique such as hydrostatic testing, radiographic testing,

ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell

thickness testing. Such periodic integrity testing of bulk oil storage containers must be

conducted at a minimum frequency of every ten years and when material repairs are

performed as provided in Steel Tank Institute (STI) standard SP001-00, Section 5.0. Bulk

container testing records must be kept for the life of the container.

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This facility must also conduct integrity and leak testing of buried fuel piping at the time of

installation, modification, construction, relocation or replacement. If a section of buried

piping is exposed for any reason, it must be inspected for deterioration. Any such activity

and inspection must be documented in writing and maintained for the life of the tank system.

Periodic pressure testing may also be warranted for piping in areas where facility drainage is

such that a failure might lead to a spill event. [40 CFR Section 112.7(e)(3)]

The following records should be maintained for the operational life of each tank:

Original tank and system installation records, design specifications, and operation and

maintenance manuals;

Records of modification to the storage tank or storage tank system;

Any permits issued for the storage tank system;

Current registration certificates;

Routine inspection and maintenance checklists;

Third-party inspection reports;

Education Sessions; and

Reports and comparison records of tank and pipe testing.

XXI. PORTABLE OIL STORAGE – 40 CFR 112.8 (C)(11)

TWU uses a portable truck-mounted 100 gallon single wall steel tank used to refuel

emergency generator ASTs with diesel. At night and during times the truck is not used, it is

parked at the FMC Service Center Auto Shop.

XXII. FACILITY TRANSFER OPERATIONS – 40 CFR 112.8 (D)

Facility transfer operations are limited to the conveyance of oil from the fill port to the

associated tank. Unusual conditions, leaks, or other problems with piping and valves will be

documented during visual tank inspections and immediately corrected. Fuel transfer piping

servicing the ASTs and USTs is located immediately at the tank such that damage due to

vehicular traffic is unlikely.

In accordance with 40 CFR 112.8(d)(1), TWU must provide any buried fuel piping installed

or replaced after August 16, 2002, with a corrosion protective wrapping and coating. The

facility must also cathodically protect these buried piping installations or otherwise satisfy

the applicable corrosion protection standards for piping under the federal regulations 40 CFR

Part 280.

Transport personnel must have available, or have ready access to, spill response materials

such as absorbent material, drain covers, and other material to limit impacts due to

unforeseen events.

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XXIII. SPILL RESPONSE AND EMERGENCY PROCEDURES

Spill prevention practices are ensured through the use of proper fuel loading and handling

procedures, through the practice of regular maintenance and inspection of the tank and

container storage systems, and through security measures, thereby minimizing the potential

for a spill or release associated with petroleum storage at the facility.

Emergency spill control and response equipment must be available at readily accessible

locations throughout the facility. Emergency spill control equipment may include sorbent

materials (e.g., granular absorbent), oil sorbent booms, oil sorbent pads, drain covers,

protective gloves, and safety glasses/goggles.

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If a spill or release of oil is discovered; follow the procedure listed in Appendix 1

Emergency Contact List:

A. Matt Moustakas, Office: 940-898-2924

Director of Environmental, Safety and Health Mobile: 940-465-4084

B. Central Plant

Alternate Contact 24-Hour: 940-898-3170

Other important numbers:

a. TWU Department of Public Safety (DPS) 940-898-2911

b. Denton Fire Department Emergency: 911

Non-Emergency: 940-349-8200

c. Texas Health Presbyterian Hospital Emergency: 940-898-7059

3000 N I35, Denton General: 940-898-7000

d. Spill Response Contractor (Green Planet): Office: 972-636-1515

Mobile: 214-325-5343

e. State of Texas Spill-Reporting Hotline and the SERC 800-832-8224

f. Texas Commission on Environmental Quality (TCEQ)

Region IV Fort Worth Office 817-588-5800

g. Environmental Protection Agency (EPA)

National Response Center (NRC) 800-424-8802

EPA Region VI - 24 hr. Spill Reporting 866-372-7745

h. City of Denton – Wastewater Treatment 940-349-8610

i. Local Emergency Planning Committee (LEPC) 940-349-2840

j. CHEMTREC 800-424-9300

(CHEMical TRansportation Emergency Center)

Regulatory Agency Reporting:

Reporting should only be completed by the Director of Environmental, Safety and

Health.

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Ensure the Initial Notification Form, located in Appendix 3, has been completed. The

information contained in the form will be provided to the regulatory agencies as

appropriate.

Texas Commission on Environmental Quality (TCEQ)

Spills to water bodies or spills of 25 gallons or greater to land should be reported

as soon as possible. If a surface oil spill is reported within 2 hours (and promptly

removed) the responsible party is not subject to any fines or civil penalties.

National Response Center (NRC) or EPA Region VI Response Center

A discharge of oil into a waterway that results in a film or sheen upon the surface

of the water must be reported immediately to the NRC, also known as EPA

Region VI Response Center (per 40 CFR 110.6). The following information

should be available before calling:

o Name, address, and telephone number of the individual filing the report;

o Name, address, and telephone number of the facility;

o Date, time, and location of the incident;

o Type of material discharged;

o A brief description of the circumstances causing the incident;

o Description and estimated quantity by weight or volume of the materials

involved;

o An assessment of any contamination of land, water, or air that has occurred

due to the incident;

o Damages or injuries caused by the discharge;

o Actions taken to stop, remove, and mitigate the effects of the discharge;

o Whether an evacuation may be necessary; and

o Names of individuals or organizations that have been contacted.

EPA Regional Administrator

Spill information must be reported to the EPA Regional Administrator within 60

days if either of the following thresholds is reached.

o Discharge more than 1,000 gallons of oil into or upon the navigable waters of

the United States or adjoining shorelines in a single discharge;

-or-

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o Discharge more than 42 gallons of oil in each of two discharges into or upon

navigable waters of the United States or adjoining shorelines, occurring within

any 12-month period.

The report is to contain the following information.

o Name of the facility;

o Your name;

o Location of the facility;

o Cause of the discharge;

o Corrective actions and/or countermeasures taken including adequate

description of equipment repairs and/or replacements;

o Maximum storage or handling capacities;

o Description of the facility, including maps, flow diagrams, and topographical

maps;

o Additional measures taken (preventative) or contemplated to minimize the

possibility of recurrence, and

o Information the regional administrator may reasonably require pertinent to the

Plan or discharge.

City of Denton Wastewater Treatment

Contact the City of Denton as soon as possible if a significant quantity of oil is

discharged to the sanitary sewer system.

TWU is responsible for all reporting and documentation procedures required under the Oil

Pollution Prevention Regulations (40 CFR Part 112).

XXIV. PLAN IMPLEMENTATION – 40 CFR 112.3(A)

Recommendations for facility improvements and/or purchase of spill control equipment or

supplies (e.g., spill kits, drain covers, dikes, mats, etc.) described in this plan shall be

constructed and/or purchased and deployed as soon as possible. Recommendations for testing

of bulk storage containers should be completed as soon as possible, but not later than November

10, 2010, in compliance with the implementation schedule provided at 40 CFR 112.3(a) [see

April 1, 2009, FR Vol. 74 No. 117 pp 29136-29142].

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FIGURES

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Figure 1 - Site Vicinity MapTexas Woman’s University

Denton, Texas 76209

Scale: N/ASpill Prevention Control and Countermeasure

(SPCC) Plan

AMEC Project #: 1167172070

Date: September 2011

U.S. Geological Survey Topographic Map1978 Denton East & 1973 Denton West Quadrangles

Subject Property

NORTH

Expansion Areas

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LIBRARY

STUDENT

CENTER

ADMISSIONS

BLDG.

UNIV. HOUSE

SERVICE

HUBBARD

HALL

POOL

CHAPEL

JONES HALL

STODDARDACT

GREENHOUSE

PATIO

BLDG.

ADMIN. DR.

DANCE &

GYM.LAB.

SOFTBALL

STARK

GUINN

POWER

TENNIS

BELL AVENUE

UNIVERSITY DRIVE

HALL

PIONEER

OAKLAND AVENUE

NORTH LOCUST AVENUE

INST. DEV.

AMPHITHEATER

BLDG.

7

PARK

AREA

TEXAS

POND

ROCK GARDEN

8

PARKING

LOT

PROPOSED

WELL SITE

NO. 4

POWER PLANT

STARK

PIONEER

VISITOR

TENNIS

OAKLAND NORTH

LIBRARY EAST

LIBRARY WEST

GUINN

JONES

CONC.

220+00

ICV

ICV

ACCESS

UTILITY

CONC.

CONC.

CHILLER

ALUMNI

ELEC SUB

COOLING

TOWER

COMMONS

Xref TWU-SPRees.dwg

SOCCER

FIELD

G

G

G

GG

T

T

TT

T

T

T

BUILDING A1BUILDING A2

BUILDING A3

BUILDING A4

BUILDING A5

CLUBHOUSE

BUILDING B1 BUILDING B2

H.C.H.I.3rd FLOOR

H.I.3rd FLOOR

H.C.

H.I.3rd FLOOR

H.C.

H.I.2nd FLOOR

H.C.

H.C.

H.C. H.I.2nd FLOOR

H.C. H.I.2nd FLOOR

H.C.T

T

T

T

T

T

T

G

Concession Stand Area

FACILITIES

ABOVEGROUND

FUEL TANKS

PLOT SCALE: 1" = 80'

TG

Oil-filled transformer

Emergency generator

Direction of surface drainage

0 50 100 150

1" = 50'-0"

LEGEND

T

TT

T

TT

T

T

FITNESS

CENTER

T

T

GT

T

T

T

T

1

FIGURE 2 SITE PLAN

2

PROJECT NUMBER

SHEET

OF

PHYSICAL PLANT SERVICES CENTER DENTON, TEXAS

TEXAS WOMAN'S UNIVERSITY

FACILITIES MANAGEMENT & CONSTRUCTION DEPT.

UPDATED

REVISIONS

BY AMEC

E&E, Inc.

08/11

1167172070

R

WXE

T

A S

U

E

ITN

LA

UVN I

CS

E

I

SA

M

O

N'

T

MEN EATIV

YIS

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BELL AVENUE

CENTER

ADMISSIONS

BLDG.

OLD MAIN

UNDERGRAD.

SCIENCE

LAB.

SCIENCE

BLDG.

SERVICE

CENTER

GREENHOUSE

JONES HALL

STODDARD

ASB

ACT

GRAD. RES.

BLDG.

MCL

PATIO

BLDG.

BRALLEY

ANNEX

HUMAN

DEVEL.

BLDG.

ART BLDG.

MUSIC

BLDG.

CFO

H.R.

CLUBHOUSE

TEXAS STREET

HANN STREET

OAKLAND AVENUE

SAWYER STREET

THIRD STREET

VINE STREET

FRAME STREET

EAST COLLEGE STREET

PIRTLE STREET

SCHMITZ STREET

GROVE STREET

MINGO ROAD

9

UNDERGROUND

FUEL TANKS

FUEL

PUMPS

2"

2"

2" VENT LINES

10000

GAL.

1000

GAL.

9

ASPHALT DRIVE

PARKING

LOT

PROPOSED

WELL SITE

NO. 3

MCL EAST

MCL SOUTH

ULB

TEXAS STREET

MARGO

OAKLAND SOUTH

MCL NORTH

JONES

GOLF

CART STORAGE

GOLF

MARK.

& COMM.

FRAME STREET

VINE STREET

NEW WALK

NEW BENCH

NEW RED TIPS

NEW WALK

NEW BENCH

NEW RED TIPS

NEW CURB

RAMP

NEW

STRIPINGLIVE OAK

TO REMAIN

LIVE OAK

TO REMAIN

CRYPE MYRTLE

TO REMAIN

CRYPE MYRTLE

TO REMAIN

LIVE OAK

TO REMAIN

NEW

LIVE OAK

NEW

LIVE OAK

NEW

LIVE OAK

CRYPE MYRTLE

TO REMAIN

STEP

WALKWALK

WALK

WALK

PIONEER CIRCLE

LANDSCAPE

NEW LAYOUT

G

G

G

G

GG

T

T

T

T

T

T

T

T

T

T

T

T

TEXAS STREET

FACILITIES

Auto Shop

PLOT SCALE: 1" = 80'

TG

Oil-filled transformer

Emergency generator

Direction of surface drainage

0 50 100 150

1" = 50'-0"

LEGEND

T

T

T

TG

T

T

T

1

FIGURE 2 SITE PLAN

2

PROJECT NUMBER

SHEET

OF

PHYSICAL PLANT SERVICES CENTER DENTON, TEXAS

TEXAS WOMAN'S UNIVERSITY

FACILITIES MANAGEMENT & CONSTRUCTION DEPT.

UPDATED

REVISIONS

BY AMEC

E&E, Inc.

08/11

1167172070

R

WXE

T

A S

U

E

ITN

LA

UVN I

CS

E

I

SA

M

O

N'

T

MEN EATIV

YIS

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

Generated by: AMEC/MJM

X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc

TABLES

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GENERATOR ADMIN BRALLEY STARK* GUINN* POWER PLANTLOCATION South side Northeast side Between Stark & Guinn Between Stark & Guinn Southwest cornerSWITCH LOC. Data center Machine room Machine room Machine room Northeast corner MANUFACTURER Cummins Cummins Cummins Cummins KatolightMODEL # DFAB-4491107 DGEA-3377508 50DGHE 50DGHE D600FRZ4SERIAL # K00177669 I990982684 G030528325 G030528326 WA525336KVA RATING 287.5 156.3 62.5 62.5 287.5KW RATING 230 125 50 50 230PEAK KW USAGE 118 110 17 23.2 133VOLTS 120/208 120/208 277/480 277/480 277/480ENGINE MFG Cummins Cummins Cummins Cummins CumminsENGINE MODEL # LTA10-G1 6CT8.3-G2 B3.3-G2 B3.3-G2 VTA28-G5ENGINE SERIAL # 35023855 45886920 68014345 68014343 25262341KEY CH751 CH751 CH751 CH751 CH545FUEL TANK (Gal) 550 336 140 140 1,320FUEL USEAGE (GPH) 18.4 6.7 3.9 3.9 17.8YEAR INSTALLED 2001 1999 2003 2003 2000FAILURE TYPE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SEFAILURE RATE gradual to instantaneous gradual to instantaneous gradual to instantaneous gradual to instantaneous gradual to instantaneous

GENERATOR ACT* SCIENCE LIBRARY HUBBARDLOCATION Machine room Southwest corner NW corner of IDB Southwest cornerSWITCH LOC. Machine room Machine room Machine room Machine roomMANUFACTURER Cummins Cummins Cummins CumminsMODEL # 80DSFAE-545611 250DQDAA DFEG-546117 80DSFAESERIAL # F090009305 F090006701 G090012989 F080191079KVA RATING 100 312.5 438 100KW RATING 80 250 350 80PEAK KW USAGE 44 45.8 87.2 25.1VOLTS 120/208 120/208 277/480 120/208ENGINE MFG Cummins Cummins Cummins CumminsENGINE MODEL # QSB5-G3 NR3 250DQDAA QSX15-G9 QSB5-G3 NR3ENGINE SERIAL # 73004276 79379539 21952765KEY CH751 CH751 CH751 CH751FUEL TANK (Gal) 140 500 600 140FUEL USEAGE (GPH) 6.9 17.3 24.1 6.9YEAR INSTALLED 2009 2009 2010 2009FAILURE TYPE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SEFAILURE RATE gradual to instantaneous gradual to instantaneous gradual to instantaneous gradual to instantaneous

GENERATOR GRB* MCL FMCLOCATION North side East side West sideSWITCH LOC. Machine room Machine room North wallMANUFACTURER Cummins Cummins CumminsMODEL # 125DSGAB 60DSFAD 150DSGACSERIAL # G100142563 G100142569 F080191078KVA RATING 156 75 188KW RATING 125 60 150PEAK KW USAGE 46 10.6 68VOLTS 277/480 277/480 120/208ENGINE MFG Cummins Cummins CumminsENGINE MODEL # QSB7-G3 NR3 QSB5-G3 NR3 QSB7-G3 NR3ENGINE SERIAL # 46900009KEY CH751FUEL TANK (Gal) 309 140 308FUEL USEAGE (GPH) 10 5.7 12.25YEAR INSTALLED 2010 2010 2009FAILURE TYPE CF, PL, PM, OF, SE CF, PL, PM, OF, SE CF, PL, PM, OF, SEFAILURE RATE gradual to instantaneous gradual to instantaneous gradual to instantaneous

CF - corrosion failure OF - overfill * Need drain blocks for storm or floor drainsPL - piping leak PM - pump malfunction

SE - spill event HF - hydraulic failure

TABLE 1 EMERGENCY GENERATOR LIST

Texas Woman's University Denton, Texas

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Site Designation Building Served

Kva Capacity Gallons Failure Type Failure Rate PCB

T-11 Steam Plant 500 200 CF, PL, PM, OF gradual to instantaneous N

T-21 Little Chapel 50 82 CF, PL, PM, OF gradual to instantaneous N

T-31 University House 75 120 CF, PL, PM, OF gradual to instantaneous N

T-41 Guinn Hall 1500 390 CF, PL, PM, OF gradual to instantaneous N

T-42 Stark Hall 1500 390 CF, PL, PM, OF gradual to instantaneous N

T-73 IDB Building 150 130 CF, PL, PM, OF gradual to instantaneous N

T-74 Fitness Center 500 200 CF, PL, PM, OF gradual to instantaneous N

T-81 Concessions Building 50 82 CF, PL, PM, OF gradual to instantaneous N

T-82 Tennis Courts 225 160 CF, PL, PM, OF gradual to instantaneous N

T-91 Soccer Field 150 130 CF, PL, PM, OF gradual to instantaneous N

T-101 Pioneer Hall 1500 390 CF, PL, PM, OF gradual to instantaneous N

T-111 DGL Building 150 130 CF, PL, PM, OF gradual to instantaneous N

T-112 Ampitheater 150 130 CF, PL, PM, OF gradual to instantaneous N

T-121 Student Center 750 270 CF, PL, PM, OF gradual to instantaneous N

T-131 Stoddard Hall 225 160 CF, PL, PM, OF gradual to instantaneous N

T-135A Mary Jones Hall 225 160 CF, PL, PM, OF gradual to instantaneous N

T-136A Service Center 150 130 CF, PL, PM, OF gradual to instantaneous N

T-141 MCL Building 500 200 CF, PL, PM, OF gradual to instantaneous N

T-142 CFO Building 500 200 CF, PL, PM, OF gradual to instantaneous N

T-151 Old Main 225 125 CF, PL, PM, OF gradual to instantaneous N

T-152 HDB Building 225 137 CF, PL, PM, OF gradual to instantaneous N

T-161 Science Building 750 405 CF, PL, PM, OF gradual to instantaneous N

T-162 Bralley Annex 112.5 125 CF, PL, PM, OF gradual to instantaneous N

T-171 ULB Building 150 130 CF, PL, PM, OF gradual to instantaneous N

T-181 Fine Arts 150 130 CF, PL, PM, OF gradual to instantaneous N

T-191 Margo Jones 500 200 CF, PL, PM, OF gradual to instantaneous N

T-192 Music Building 150 130 CF, PL, PM, OF gradual to instantaneous N

T-201 ASB Building 500 200 CF, PL, PM, OF gradual to instantaneous N

TABLE 2 OIL-FILLED TRANSFORMER LIST

Texas Woman's University Denton, Texas

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Site Designation Building Served

Kva Capacity Gallons Failure Type Failure Rate PCB

TABLE 2 OIL-FILLED TRANSFORMER LIST

Texas Woman's University Denton, Texas

T-202 GRB Building 750 270 CF, PL, PM, OF gradual to instantaneous N

T-212 Patio Building 75 120 CF, PL, PM, OF gradual to instantaneous N

T-221 Admissions Building 225 160 CF, PL, PM, OF gradual to instantaneous N

T-241 Chiller Plant 5000 970 CF, PL, PM, OF gradual to instantaneous N

T-250 Lowry Woods 1000 320 or 350 CF, PL, PM, OF gradual to instantaneous N

T-252 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

T-253 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

T-254 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

T-255 Lowry Woods 167 162 CF, PL, PM, OF gradual to instantaneous N

T-256 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

T-257 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

T-258 Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

Lowry Woods 250 162 CF, PL, PM, OF gradual to instantaneous N

Mary Jones Hall along street 750 270 CF, PL, PM, OF gradual to instantaneous N

8,672 gal

CF - corrosion failure OF - overfill

PL - piping leak PM - pump malfunction

SE - spill event HF - hydraulic failure

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EBLI # Decal # Bldg # Building NameLast Inspection

Install/ModDate Failure type Rate

11010 40323 44 Stark Guinn Commons 6/22/2012 2000 PM, OF, HF gradual to instantaneous

13039 22948 79 Pioneer Hall 6/22/2012 1997 PM, OF, HF gradual to instantaneous

4008 42129 30 Hubbard Hall 6/22/2012 2002 PM, OF, HF gradual to instantaneous

4009 49933 37 Stoddard 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4009 49934 37 Stoddard 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4010 9533 35 Library 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4010 9534 35 Library 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4011 9542 39 Jones Hall 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4012 56613 64 Student Center 6/22/2012 2004 PM, OF, HF gradual to instantaneous

4012 59291 64 Student Center 6/22/2012 2004 PM, OF, HF gradual to instantaneous

4013 49931 4 G R B 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4014 9543 62 D G L 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4015 49688 3 A S B 6/22/2012 2003 PM, OF, HF gradual to instantaneous

4016 49603 5 Margo Jones Hall 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4017 50832 6 Fine Arts 6/22/2012 2004 PM, OF, HF gradual to instantaneous

4018 9541 12 Old Main 6/22/2012 1993 PM, OF, HF gradual to instantaneous

4019 9539 11 H D B 6/22/2012 2000 PM, OF, HF gradual to instantaneous

4020 36860 9 Science (south) 6/22/2012 2011 PM, OF, HF gradual to instantaneous

4020 77564 9 Science (north) 6/22/2012 2010 PM, OF, HF gradual to instantaneous

35532 80722 102 Fitness & Recreation 6/22/2012 2011 PM, OF, HF gradual to instantaneousCF - corrosion failure OF - overfillPL - piping leak PM - pump malfunctionSE - spill event HF - hydraulic failure

TABLE 3 HYDRAULIC ELEVATOR LIST

Texas Woman's University Denton, Texas

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Type of Container LocationDate

InstalledContents/Capacity

(gallons)Tank/Pipe Material

Secondary Containment

Failure Type Rate Flow Direction

AST1 Central Plant 2001 diesel/15,000 steel/steel double wallCF, PL, PM, OF

gradual to instantaneous To ground then to south

AST2 Central Plant 2001 diesel/15,000 steel/steel double wall

CF, PL, PM, OF

gradual to instantaneous To ground then to south

Used oil container Central Plant NA used oil/55 steel/NA double wall

CF, PL, PM, OF

gradual to instantaneous To ground then to south

Sand TrapFacilities Service

Center unkn 1000 concrete/NA NA OF, SE NA NA

Oil Water SeparatorFacilities Service

Center unkn 1000 concrete/NA NA OF, SE NA NAOil Water Separator Student Center unkn 300 concrete/NA NA OF, SE NA NAOil Water Separator Student Center unkn 500 concrete/NA NA OF, SE NA NAOil Water Separator Student Center unkn 200 concrete/NA NA OF, SE NA NAOil Water Separator Guinn/Stark unkn 1000 concrete/NA NA OF, SE NA NAOil Water Separator Hubbard unkn 300 concrete/NA NA OF, SE NA NA

Used Grease Container Student Center 2013 cooking grease/110 NA/NA None SE, OFgradual to

instantaneous To concrete within loading dock area

55-gallon Drum

Human Development

Building Nutrition and Food Sciences

kitchen ∆ NA cooking grease/55 NA/NA None SE, OFgradual to

instantaneous To floor and potentially to floor drain

55-gallon DrumFacilties Service

Center NAused oil/various

quantities steel/NA Drum pallet SE, OFgradual to

instantaneousContained within drum pallet. If spilled inside building prior to placement on pallet, would flow to OWS.

55-gallon DrumFacilties Service

Center NAnew oil/various

quantities steel/NA Drum pallet SE, OFgradual to

instantaneousContained within drum pallet. If spilled inside building prior to placement on pallet, would flow to OWS.

Used oil containerFacilities Service

Center NA approximately 500 steel/NA double wallCF, PL, PM, OF

gradual to instantaneous To concrete inside building

UST1Facilities Service

Center 6/1/1998 gasoline/10,000 steel/steel double wallCF, PL, PM, OF

gradual to instantaneous To concrete then to north towards FMC

UST2Facilities Service

Center 6/1/1998 diesel/1,000 steel/steel double wallCF, PL, PM, OF

gradual to instantaneous To concrete then to north towards FMC

Truck-mounted AST

Auto Shop at Facilities Service

Center unkn diesel/100 steel/poly flex NoneOF, SE, PL, PM

gradual to instantaneous To pavement then adjacent soil

CF - corrosion failure OF - overfill unkn - unknown

PL - piping leak PM - pump malfunction NA - not applicable

SE - spill event HF - hydraulic failure OWS - oil water separator

∆ Need drain block for floor drains

TABLE 4 MISCELLANEOUS OIL-CONTAINING EQUIPMENT LIST

Texas Woman's University Denton, Texas

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

Generated by: AMEC/MJM

X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc

TABLE 5

SPILL HISTORY

Texas Woman’s University

Denton, Texas

Written Description of Spill Corrective Actions Taken Plan for Preventing

Recurrence

10/13/09 ~2PM: One of the TWU busses

was just refueled and parked on the hill to

the south of the Auto Shop. Auto shop

personnel subsequently noticed oil sheen

spreading across the parking lot around

both sides of the fuel island and tracked it

back to the bus. It appears that a small

amount of diesel fuel leaked from around

the fuel filler cap and that the fuel tank may

have been overfilled and leaked out when

parked on the slope.

FMC auto shop personnel used

absorbent pads, socks and granular

absorbent to soak up the sheen across

the paved area. The rainwater was

running south and north from the auto

shop area, and small quantities of

sheen or sludge appears to have

reached the grass areas where this

water discharges from the paved areas.

All absorbent materials were swept up

as much as possible and placed in a 55

gallon drum along with PPE for proper

disposal.

Auto Shop personnel to check to

make sure there is no issue with the

fuel tank on the bus and instruct

personnel not to over fill the fuel

tank when refueling.

11/09/09 ~10PM: DPS notified the FMC

Auto Shop of an incident involving thefts

of items from cars parked in the Pioneer

Hall parking lot which was discovered the

morning of Monday, November 9th. DPS

estimated that the thefts occurred at

approximately 10 PM, Sunday night

November 10. The thieves also tried to

siphon gas from at least one of the vehicles,

resulting in spillage in the relatively flat

area of the lot between the last two rows of

cars. When found, the fuel was mixed with

rain water, and there was a strong odor of

gasoline in the areas as it evaporated. Matt

Moustakas inspected the area and found no

evidence that the spill had migrated off of

the pavement, and there are no storm drains

in the area.

The FMC auto shop responded by

obtaining granular absorbent, brooms,

shovels and a waste container. The

granular absorbent was used to absorb

all of the gasoline/stormwater mixture

and placed in a drum of used

absorbent in the auto shop from the

previous incident for proper disposal

during the next waste disposal event.

None.

08/02/11: Time unknown; FMC was

notified that one of the grease traps in the

loading dock areas south of the Student

Union had backed up at some point in the

last couple of days. An unknown small

quantity of grease/water had discharged to

the concrete loading dock drive, and some

portion of the liquid had reached the

adjacent trench drain, and vehicles had

begun to track the material.

There was no flowing liquid by the

time FMC personnel arrived on scene,

only residual materials on the

concrete. FMC personnel capped off

the discharge pipe from the trench

drain, placed a sump pump in the

trench drain that was arranged to

discharge to the nearby sanitary sewer

cleanout, and then proceeded to power

wash the concrete with detergent and

None

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

5470 Created 1/30/10

Generated by: AMEC/MJM

X:\My Shared Folders\FacMgt\ENVIRONMENTAL SAFETY & HEALTH\Spill Response-SPCC\SPCC Plan\2014\SPCC Plan 2014.doc

Written Description of Spill Corrective Actions Taken Plan for Preventing

Recurrence water. The City of Denton was

notified of the cleanup approach prior

to commencing the discharge to the

sanitary sewer.

08/27/11: 7:30 pm; TWU housing

personnel were notified of a car with a

leaking gas tank in the Guinn Hall Parking

lot. TWU DPS was summoned who in turn

summoned the Denton Fire Department.

The Denton Fire Department used

granular absorbent on the gasoline

leak (estimated at a few gallons), and

took the resulting material with them

for disposal. The car was impounded

by TWU DPS. Matt Moustakas was

not notified until 9/7/11 and will be

notified by DPS of any leaks or spills

going forward.

None

2/29/12: The custodians working in the

student union notified their supervisors that

there were significant quantities of kitchen

grease spilled around the kitchen grease

collection tank outside the student union

loading dock. It appears that some of the

buckets used to transfer grease from the

kitchens to this tank had spilled and/or

some material had been spilled over time

when transferring the buckets contents.

The TWU employee responsible for

food services as well as the Aramark

(food service contractor) contact were

notified and the area was cleaned.

Aramark employees were reminded

of proper grease handling

procedures.

3/14/12 4:30 PM; A visitor to the campus

was cutting though the grass area between

the MCL parking lot and parking lot north

of Jones Hall with his motorcycle. He

rolled over the curb and damaged the oil

pan on the bottom of the motorcycle and

did not realize it. He proceeded to drive out

of the parking lot and east along

administration drive until he stopped in the

parking lot south of Jones hall once he

realized the motorcycle was leaking. The

majority of the trail of oil was a very

small/thin layer due to the speed of the

motorcycle and the size of the leak. The

heavier puddles of oil were on either end of

the trail.

Auto Shop Supervisor and Matt

Moustakas used absorbent pads to

recover as much of the oil from the

heavier areas as possible, but a large

stain remained.

None

11/20/12: FMC landscaping employee

reported an automotive oil leak which

appears to have occurred over night as the

oil had run downhill several spaces east

and what appeared to be sprinkler water

was mixed with the oil.

The car that lost the oil appeared to

have been moved prior to reporting of

the spill. Eric Hutmacher (Safety

Officer) notified DPS in an attempt to

locate the owner of a car parked over

part of the oils spill. Two automotive

shop employees and two Risk

Management employees used

absorbent spill pads to absorb the free

liquids followed by oil-dri to absorb

the residual oil, including under the

parked car. Resulting materials were

Encourage all employees to report

spills of any kind to DPS and Risk

Management as soon as possible.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

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Written Description of Spill Corrective Actions Taken Plan for Preventing

Recurrence disposed of in the normal trash as

there were no free liquids in the

resulting waste.

7/11/13: Hydraulic leak from crane being

used by roofing contractor. Leaked

hydraulic fluid was contained by concrete

sidewalk and road with the exception of a

small amount that appears to have entered

the grass to the side of the sidewalk.

Roofing contractor cleaned up the

hydraulic oil with granular absorbent.

Encourage contractors to ensure

proper maintenance is conducted

on their equipment and to

immediately report spills to TWU

Construction Observer.

8/27/2013: Received a call from a TWU

student that a scooter was on its side

leaking gas and oil.

Scooter was actually off campus, but

Risk Management employee

responded and soaked up gas and oil

and disposed of the resulting material

in the auto shop absorbent disposal

drum.

N/A: Not on TWU property.

7/5/14: During normal patrol, TWU DPS

found a car that had been involved in an

accident the evening before that was now

parked in the Lowry Woods parking lot and

was leaking transmission fluid.

DPS contacted Risk Management and

Matt Moustakas responded.

Transmission fluid was absorbed using

spill pads as well as possible. Some

fluid escaped the concrete lot via the

expansion cracks. Response materials

disposed of in normal trash as there

were no free liquids.

Encourage all employees to report

spills of any kind to DPS and Risk

Management as soon as possible.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

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TABLE 6

SPILL PREVENTION EQUIPMENT

Texas Woman’s University

Denton, Texas

Equipment Overfill

Protection Spill Kit Location

AST 1 & 2;

UST 1 & 2

Veeder-Root ATG

systems

Spill kits (sorbent, pads, etc.) to be maintained in the

Central Plant and FMC Service Center(1)

Cooking Grease Inspect container

level prior to filling

Spill kits (sorbent, pads, etc.) to be maintained in the

vicinity of kitchen areas(1)

Generator ASTs Sight gauge on tank

Provide appropriate drain covers for and a small spill kit

to be maintained on the truck used to refill the generator

ASTs(1)

Used oil AST,

FMC Golf Cart

Barn

Sight gauge on tank Spill kit (sorbent, pads, etc.) to be maintained in the

adjacent FMC Service Center(1)

Used oil AST,

Central Plant

Visual inspection

during filling

Spill kit (sorbent, pads, etc.) to be maintained in the

Central Plant(1)

(1) Spill response supplies shall be located in a location readily accessible during fueling events

and to allow access during spill events.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

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Appendix 1

Procedures

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FMC Procedure

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Texas Woman’s University Oil Spill Response Procedure

In the event of an oil spill, the following procedures shall be followed:

1. Contact TWU Department of Public Safety (DPS) (940-898-2911 or x2911) if there is

imminent threat of fire or other life-threatening situation.

2. Identify the source of the leak or spill and attempt to stop the flow of oil, if practicable

without endangering personnel.

3. If the spill is beyond the capabilities of TWU personnel or equipment, immediately

contact outside spill response contractors for assistance. Place sorbent materials or drain

covers to prevent oil from reaching navigable waters or sanitary sewer drains. Sorbent

materials shall be placed at catch basins and drainage openings (i.e., floor drains).

Sorbent materials should also be placed across downgradient pathways if necessary to

impede the flow of oil. Drain covers should be placed over floor drains, storm drains,

and oil/water separator inlets.

4. Contact the Director of Environmental, Safety and Health (during normal business hours)

or the Central Plant (alternate/24-hours) at the telephone numbers listed below.

A. Matt Moustakas, Work: 940-898-2924

Director of Environmental, Safety and Health Mobile: 940-465-4084

B. Central Plant

Alternate Contact 24-Hour: 940-898-3170

5. Cordon off the area if necessary to prevent personnel and traffic from entering the area.

Contact DPS for assistance with traffic/crowd control at (940-898-2911 or x2911).

6. Collect or absorb the spilled materials once the spill is contained. Large spills may

require outside cleanup contractors to be called in to collect the spilled material.

7. Collect all spill response materials (oil-containing sorbents/pads/etc.) and used Personal

Protective Equipment (PPE) and place in intact buckets or drums. The Director of

Environmental, Safety & Health will arrange for proper disposal of all spill response

materials.

8. Contact the relevant individuals and agencies on the emergency contact list as directed by

the Director of Environmental, Safety and Health.

Ensure the Initial Notification Form, located in Appendix 3, has been completed for each

incident. The information contained in the form will be provided to the regulatory

agencies as necessary.

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FMC Procedure

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Texas Woman’s University Oil Transfer Procedure

General:

1. Keep fire away and prevent persons from smoking.

2. Park vehicle as close as possible to the fill pipe or tank receiving the product and use the

minimum length of hose possible to complete the connection between the vehicle and

the tank or fill pipe.

3. Verify that the temporary spill containment structures (e.g., drain covers or plugs) are

available nearby; covers/plugs will generally be put in place if a spill occurs. Verify that

the emergency spill containment equipment (e.g. absorbent pads, granular absorbent, oil

boom, etc.) is fully stocked at a nearby accessible location prior to beginning transfer

operations. The truck used to fuel generator tanks should also be equipped with some

emergency spill response and containment equipment (e.g., absorbent pads/socks).

4. The driver and designated TWU employee shall remain at the fill location at all times

and shall not leave the vehicle unattended during the transfer operations.

Prior to Transfer:

1. Visually check all transfer hoses for leaks and wet spots. Only use hoses in good

condition.

2. Verify that sufficient volume is available in the storage tank to receive the product to be

pumped. Determine tank capacity by level indicator, electronic inventory system, or

taped measurement and tank gauge chart.

3. Secure the loading vehicle prior to transfer operations with physical barriers such as

wheel chocks to safeguard against accidental movement and rupture of transfer lines.

Make sure that the parking brakes of the loading vehicle are set.

4. Keep hose ends tightly capped while moving hoses into position.

During Transfer:

1. When transferring liquids, shut off motors or auxiliary or portable pumps when making

and breaking hose connections.

2. Monitor all hoses and hose couplings for leaks. Prevent personnel or vehicular contact

with hoses through the use of barricades or orange traffic cones as necessary.

3. Monitor the liquid level in the receiving tank during filling operations to prevent

overflow.

4. Do not top off tank. Provide a minimum of 10 percent free space within the tank to

prevent leakage due to thermal expansion. Close valve connections if an overfill

condition occurs and withdraw sufficient liquid from the tank, if possible, to permit

complete drainage of the vent pipe and hose fill.

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

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After Transfer:

1. Close all tank and loading valves before disconnecting.

2. Securely close all vehicle internal, external, and dome cover valves before

disconnecting.

3. Make sure that all material transfer operations are complete before disconnecting any

transfer lines.

4. Secure all hatches.

5. Remove any wheel chocks that have been used.

6. Prior to vehicle departure make sure that all connections, and fill lines are disconnected.

7. After the transfer lines are disconnected and prior to vehicle departure, inspect the

outlets for evidence of leakage.

8. Make sure that the hoses or other connecting devices are drained, vented, or blown down

to remove the remaining liquid before moving them away from their connections.

9. Use a drip pan, pail, and/or oil absorbent pads when breaking a hose connection.

10. Cap the end of the hose or other connecting devices before moving them to prevent

uncontrolled oil leakage.

11. Cap associated hose risers.

12. Close all hose riser valves not in use.

13. Soak up any spilled or dripped oil from in or around the fill port and secure the fill port

cover or cap.

14. If any oil-containing sorbent material was generated during fuel transfer operations,

contacting Risk Management/Director of Environmental, Safety & Health for proper

disposal.

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FMC Procedure

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Texas Woman’s University General Handling Oil Procedures

HOUSEKEEPING

It is the responsibility of TWU employees to keep their work area clean at all times. The

following procedures will assist in meeting this responsibility.

1. Spills, no matter how small or insignificant, should be cleaned up immediately in

accordance with proper procedures.

2. Sorbent materials shall be properly disposed of in accordance with proper

procedure and only by licensed vendors. Contact Risk Management/Director of

Environmental, Safety & Health for proper disposal.

3. Immediately report large spills/leaks in accordance with the emergency spill

response protocol in this plan (See Oil Spill Response Procedure above).

LEAK DETECTION RESPONSE

In the event a leak detection alarm is activated:

1. If a leak detection alarm is found activated, notify the department responsible for

the associated oil-containing equipment and the Director of Environmental, Safety

and Health immediately.

2. If a leak is discovered which is not being contained by a double wall system,

respond in accordance with the emergency spill response procedure above.

3. If a significant leak is not apparent, inspect the piping and connections to

determine if there are any leaks. If evidence of a leak is discovered, respond in

accordance with the emergency spill response procedure above.

4. If no visible leak is located, contact FMC who will contact a State Certified

vendor to inspect the system and clear the alarm, or perform necessary repairs.

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FMC Procedure

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Appendix 2

Statement of Substantial

Harm Determination

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

Document Number: 5470.3 v.3 Review Date: 7/28/2014 FMC Division: Risk Management Approved By: AVP, FMC

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Certification of the Inapplicability of the Substantial Harm Criteria

(Attachment C-II to 40 CFR 112 Appendix C)

Facility Name: Texas Woman’s University

Facility Address: Denton, Texas

1. Does the facility transfer oil over water to or from vessels and does the facility

have a total oil storage capacity greater than or equal to 42,000 gallons?

Yes No

2. Does the facility have a total oil storage capacity greater than or equal to 1

million gallons and does the facility lack secondary containment that is

sufficiently large to contain the capacity of the largest aboveground oil storage

tank plus sufficient freeboard to allow for precipitation within any

aboveground oil storage tank area?

Yes No

3. Does the facility have a total oil storage capacity greater than or equal to 1

million gallons and is the facility located at a distance (as calculated using the

appropriate formula in Attachment C-III to Appendix C, 40 CFR 112, or a

comparable formula) such that a discharge from the facility could cause injury

to fish and wildlife and sensitive environments? For further description of fish

and wildlife and sensitive environments, see Appendices I, II, and III to

DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and

Wildlife and Sensitive Environments" (see Appendix E to 40 CFR 112, Section

10, for availability) and the applicable Area Contingency Plan.

Yes No

4. Does the facility have a total oil storage capacity greater than or equal to 1

million gallons and is the facility located at a distance (as calculated using the

appropriate formula in Attachment C-III to Appendix C, 40 CFR 112, or a

comparable formula) such that a discharge from the facility would shut down a

public drinking water intake1?

Yes No

1 For the purposes of 40 CFR Part 112, public drinking water intakes are analogous to public water systems as

described at 40 CFR 143.2(c).

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FMC Procedure

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Certification of the Inapplicability of the Substantial Harm Criteria (Continued)

Facility Name: Texas Woman’s University

Facility Address: Denton, Texas

5. Does the facility have a total oil storage capacity greater than or equal to 1

million gallons and has the facility experienced a reportable oil spill in an

amount greater than or equal to 10,000 gallons within the last 5 years?

Yes No

Certification

I certify under penalty of law that I have personally examined and am familiar with the

information submitted in this document, and that based on my inquiry of those

individuals responsible for obtaining this information, I believe that the submitted

information is true, accurate, and complete.

Signature

Matt Moustakas

Name (type or print)

Director of Environmental, Safety & Health

Title

Date

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FMC Procedure

Document Name: SPCC Plan Approval Date: 1/30/2010

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Appendix 3

Initial Notification Form

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FMC Procedure

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HAZARDOUS MATERIALS INCIDENT

INITIAL NOTIFICATION - Federal Law Requires Information in Shaded Areas

1 Date of Incident: Time of Incident: AM PM

2 Company Name:

3 Location (street, route, town, county):

4 Person Reporting: Number Calling From:

5 Call Back Name: Call Back Number:

6 Type of Incident: Spilling Leaking Pumping Pouring Emitting Discharging

7 Substance: EHS Trade Name:

DOT ID: _____________ Hazard Class: _________ CAS Number: __________-____-___

8 Physical State Stored: Solid Liquid Gas State Released: Solid Liquid Gas

Qty. Released: ___________ lbs gal ft3 Reportable Quantity: ________________ lbs

9 Container (check all that apply): Capacity: ________________ lbs gal ft3

Fixed Mobile Portable Insulated Pressurized Armorized Steel Glass

Plastic Tank Box Barrel Pipe Other:

10 Release: Complete Ongoing Confined Duration: Rate:

11 Released to: Soil Water Ocean Air Well Sewer Containment Other:

12 Wind Direction: MPH: Weather Conditions: Temp:

13 Assistance Needed: Police Fire Ambulance HazMat Team Other:

14 Health Effects/Emergency Care Instructions (if known) Injuries Fatalities

15 Description of Incident:

16 Preventative Measures:

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FMC Procedure

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16 IMPORTANT NUMBER TO CALL:

Fire Department, State Police, Emergency Response Team (911)

Texas Spill-Reporting Hotline (817-588-5800)

National Response Center (800-424-8002) Incident Number: ____________________

Spill Response Contractors

Corporate Environmental Department

17 Notification Date: Time: Received by:

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FMC Procedure

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Appendix 4

SPCC Training Outline

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FMC Procedure

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SPCC Training Outline

Texas Woman’s University

Denton, Texas

Applicable Regulations

40 CFR 112 – Oil Pollution Prevention (adopted by Texas without additions)

o Requires facilities storing petroleum products in quantities greater than 1,320

gallons above ground or 42,000 underground to develop a Spill Prevention,

Control and Countermeasures plan

o Plans must include:

Detail of each container;

Discharge prevention measures – procedural

Discharge prevention measures – structural

Discharge response measures

Inspections

Training activities

Proper Operation of Equipment

Housekeeping

Routine inspections

Operations, Policies and Procedures

Tank loading

Spill equipment location and use

Emergency Procedures

Spill response

Spill reporting

Known Spills